There is NO safe solution for radioactive fuel rods that can remain radioactive for a million years (EPA). They’re among the deadliest materials on earth. Yet, NRC’s “Nuclear Waste Confidence” game makes unsubstantiated claims that high-level radioactive wastes can be stored safely, soundly, and securely, virtually forever. This applies to nuclear plant sites like Limerick and allows them to continue producing and piling up deadly radioactive wastes under the absurd pretense that there is a safe solution.

Unthinkable devastating health and economic consequences threaten our future whether stored in fuel pools, above ground casks, from reprocessing, or from dangerous transport to a central location. NRC’s assumptions are far-fetched and negligent, including that dry cask storage systems, structures, and components can and will be entirely replaced once per century. NRC fails to identify astronomical public costs or where funds would come from for expensive massive replacements forever. NRC irrationally assumes society is willing or able to pay such costs, even if replacement is possible.

It was insanity for NRC to even consider relicensing Limerick Nuclear Plant when there is no safe solution for its deadly radioactive wastes.

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Of greatest concern are Limerick’s fuel pools, already packed beyond design capacity, and dangerously vulnerable to meltdowns with potential for unthinkable health and economic devastation. Limerick’s two fuel pools hold more than two and a half times the amount of fuel rod assemblies (6,200) than four fuel pools at Fukushima (2,400) and far more than other older U.S. nuclear plants like TMI and Oyster Creek. NRC can’t or won’t tell ACE why.

With loss of fuel pool cooling water, Limerick’s fuel rods can heat up, self-ignite, and burn in an unstoppable fire. There is no endless source of water, but May 2013, Exelon was permitted to take unlimited amounts of public water from across six counties to deal with such a disaster.

· A 2003 study shows a fire in one spent fuel pool fire could release a radioactive plume that could contaminate eight to 70 times more land than Chernobyl and render about 95,000 square kilometers of land uninhabitable.

· A spent fuel pool disaster could cause fatal radiation-induced cancer in thousands of people as far as 500 miles from Limerick. A 2004 study concluded that 44,000 near-term deaths could occur from acute radiation poisoning. People could die as far as 60 miles downwind (Philadelphia is just 20 miles downwind).

Limerick’s densely packed fuel pools are vulnerable to loss of water and meltdown through aging, accidents, natural disasters, and terrorist attacks. There is much cause for concern.

· Limerick’s roof-top fuel pools, located over reactors (like Fukushima’s), are five stories high with no outside containment. Devastating leaks could occur from terrorists’ missiles or air strikes, yet Exelon provides no protection against either.

· Limerick’s fuel pool liners are corroding and thinning at rates up to 10 times faster than anticipated. NRC staff called for immediate recoating, but Exelon was allowed to delay coating for over a decade.

· Cement originally used for Limerick’s fuel pools is substandard (verified by a Limerick quality control inspector), increasing risk for loss of water from an earthquake or terrorist attack.

NRC should close Limerick now to stop producing such deadly radioactive wastes and store it safer on site. For details: www.acereport.org #9 “High-Level Radioactive Wastes: A Ticking Time Bomb.”

What can you do? Written public comments are being accepted by NRC before November 27 on NRC’s absurd Nuclear Waste conclusions. NRC needs to receive large numbers of public comments — by webform, email, snail mail or fax. Sample comments and addresses will be available at www.beyondnuclear.org or from ACE at 610-326-2387.